Executive Summary

The Singapore Convention on Mediation (2019) marked a watershed moment for international dispute resolution by providing a harmonized framework for the enforcement of mediated settlement agreements across borders. With over 55 signatories and ratifications from major jurisdictions, the Convention promises to elevate mediation as a preferred dispute resolution method. However, adoption remains uneven, and practical challenges around enforcement, cultural perceptions of mediation, and interaction with existing arbitration frameworks persist. This policy brief examines these issues and provides recommendations for governments, institutions, and practitioners.

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Current Context

1. The Singapore Convention on Mediation (2019):
   1. Offers enforceability of international mediated settlements, akin to the New York Convention (1958) for arbitration.
   1. Designed to reduce reliance on litigation and arbitration for cross-border disputes, particularly in commercial matters.
2. Global Ratification Status:
   1. As of 2025, 57 states have signed the Convention, and 14 have ratified, including Singapore, Fiji, Qatar, Belarus, and Saudi Arabia.
   1. Key jurisdictions such as the EU and the US remain hesitant to ratify, slowing its global reach.
3. Institutional Adoption:
   1. International Chamber of Commerce (ICC) and UNCITRAL are actively promoting mediation frameworks, while ODR platforms integrate Singapore Convention provisions into digital settlement processes.

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Legal and Practical Challenges

• Limited Ratification: Many trade-heavy jurisdictions (e.g., the US, India, EU bloc) have not ratified, weakening the Convention’s universality.
• Cultural Barriers: In some regions, mediation is seen as a “soft” or less authoritative process compared to arbitration, affecting uptake.
• Interaction with Arbitration: Businesses accustomed to arbitration may hesitate to rely solely on mediation, especially where enforceability remains uncertain.
• Judicial Interpretation: Early enforcement cases will set precedents; lack of clarity on court involvement in settlement enforcement could create inconsistencies.

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Comparative Insights

Jurisdiction	Approach to Mediation Enforcement
Singapore	Fully ratified; courts are supportive of mediated settlements.
Qatar & Saudi Arabia	Ratified quickly to bolster status as international dispute hubs.
EU	Still deliberating; some members rely on the EU Mediation Directive instead.
India	Passed Mediation Bill 2023 but has not ratified the Singapore Convention.

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Policy Recommendations

1. Promote Ratification Among Trade Partners
   1. Governments should prioritize ratification to build predictability in cross-border commerce.
2. Judicial Training
   1. Courts must be trained on handling mediated settlement enforcement, ensuring uniform application.
3. Hybrid Models (Med-Arb)
   1. Encourage adoption of med-arb mechanisms that combine mediation flexibility with arbitration enforceability.
4. Institutional Capacity Building
   1. Law firms and chambers should train mediators with cross-cultural competence and digital mediation skills.
5. Public Awareness Campaigns
   1. Businesses must be educated on mediation’s efficiency and enforceability under the Convention.

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Implications for Stakeholders

• Businesses: Lower transaction costs and faster resolution if the Convention is widely adopted.
• Law Firms: Expansion of mediation practices and advisory services.
• Governments: Ratification could improve investment climate by demonstrating commitment to efficient dispute resolution.

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Conclusion

The Singapore Convention is a milestone in elevating mediation as a trusted mechanism for cross-border dispute resolution. To realize its potential, ratification must accelerate, institutional support must deepen, and cultural perceptions of mediation must evolve. With proper implementation, the Convention can reshape international dispute resolution by creating a global enforcement mechanism for consensual settlements.

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References

• UNCITRAL, Singapore Convention on Mediation (2019): UNCITRAL.org
• Nadja Alexander & Shouyu Chong, The Singapore Convention on Mediation: A Framework for the Cross-Border Recognition of Mediated Settlements (Kluwer, 2020).
• Ministry of Law, Singapore: “Status of Ratification – Singapore Convention” (2025 update).
• Indian Ministry of Law, Mediation Bill 2023.